Tama Kudman and Robert Gordon note that President Trump’s Justice Department appears to be taking a more selective approach in criminal enforcement involving
digital assets, in their article “Justice Department shifts some priorities in
digital asset enforcement.”
As of today, the CTA is in force and FinCEN has set a new deadline to comply with the Reporting Rule of March 21, 2025. We recommend that all Reporting Companies and Beneficial Owners prepare to file in accordance with this deadline.
In an unexpected development, on December 26, 2024, the Fifth Circuit issued an Order vacatingits December 23 decision to lift the initial stay on BOI reporting requirements.
In what amounts to slightly less than a Christmas gift, the U.S. Department of Treasury has extended generally the deadline for companies required to file and created or registered prior to January 1, 2024 to January 13, 2025.
Given the uncertainty around enforcement, we recommend that all Reporting Companies comply to the greatest extent possible, despite the enormous burden that may impose on some organizations.
On December 3, 2024, the Honorable U.S. District Judge Amos L. Mazzant of the Eastern District of Texas, Sherman Division, ruled on a Preliminary Injunction in Civil Action No. 4:24-CV-478.
The deadline for one or more of your entities to file a Beneficial Ownership Information Report with the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the U.S. Department of the Treasury, is quickly approaching
